Policy Statement
“APVIA Ltd conducts all business in Sierra Leone with the highest standards of integrity, transparency, and ethical conduct. This policy summarises three core policies: Anti-Bribery, Non-Corruption, and Open Door. These align with the Anti-Corruption Act 2008 (amended 2019), the United Nations Convention against Corruption (ratified 2004), and the Sierra Leone Corporate Governance Code (2018).”
Our Commitments
- Anti-Bribery: APVIA Ltd strictly prohibits bribery in all forms, direct or indirect, active or passive. No employee, director, agent, contractor, or business associate shall offer, promise, give, request, solicit, or accept any bribe, kickback, or improper advantage to influence business decisions or obtain and retain business.
- Bribery encompasses public sector bribery (any advantage to or from public officials), private sector bribery (improper advantages in commercial transactions), facilitation payments (prohibited even where locally customary), and gifts or hospitality (permitted only when reasonable, proportionate, and transparent).
- Non-Corruption: APVIA Ltd is committed to preventing corruption across all operations and fostering a culture of integrity. This policy addresses fraud, embezzlement, abuse of office, conflict of interest, money laundering, and illicit enrichment.
- Prohibited conduct includes fraud and embezzlement, abuse of office, conflict of interest (all conflicts must be disclosed), money laundering, and illicit enrichment (Section 119, Anti-Corruption Act 2008).
- Open-Door Policy: All employees, regardless of position, have access to management and can raise concerns, share ideas, or seek guidance without fear of retaliation.
- Employees are encouraged to first address concerns with their immediate supervisor. If uncomfortable, they may approach any level of management including the CEO, HR Director, or Ethics and Compliance Officer.
- All discussions are treated confidentially, subject only to legal obligations. No employee suffers adverse consequences for raising concerns in good faith; retaliation is itself a serious disciplinary offense.
Quality Practices
- Zero-tolerance approach: proven bribery results in immediate disciplinary action including termination and may be reported to the Anti-Corruption Commission (ACC)
- Risk-based due diligence conducted on all third parties and agents
- Mandatory anti-bribery training for all employees
- Segregation of duties, independent audits, and regular reviews
- Transparent and competitive procurement processes
- 24-hour independent ethics hotline and confidential email address
- Gift Register for all gifts above approved threshold
- Annual policy reviews and regular risk assessments
Other Policies
Ref: APVIA-QP-001
Quality Policy
African Projects Ventures Investments and Advancement Limited (APVIA Ltd) is committed to achieving and sustaining the highest standards of quality in all our business operations, projects, investments, and advisory services throughout Sierra Leone and across the African continent. We recognise that quality is fundamental to our success, our reputation, and the value we deliver to our clients, stakeholders, and the communities we serve.
Read PolicyRef: APVIA-HSP-001
Health and Safety Policy
African Projects Ventures Investments and Advancement Limited (APVIA Ltd) is committed to protecting the health, safety, and welfare of all its employees, contractors, clients, visitors, and any other persons who may be affected by its operations in Sierra Leone. We recognise that effective health and safety management is fundamental to our business success and is a core responsibility of management at all levels.
Read PolicyRef: APVIA-EP-001
Environmental Policy
African Projects Ventures Investments and Advancement Limited (APVIA Ltd) is committed to protecting the environment and promoting sustainable development in all its business operations, projects, and investment activities within Sierra Leone and across the African region. We recognise that our activities as business facilitators, investment promoters, and project developers have the potential to impact the environment, both directly and through the projects and ventures we support.
Read PolicyRef: APVIA-POL-DP-001
Data Protection GDPR Policy
This policy sets out the commitment of African Projects Ventures Investments and Advancement Limited (APVIA Ltd) operating in Sierra Leone to protecting personal data in accordance with the General Data Protection Regulation (EU GDPR), the Sierra Leone Data Protection Act, 2023, and other applicable international data protection standards.
Read PolicyRef: APVIA-EDI-001
Equality and Diversity Policy
African Projects Ventures Investments and Advancement Limited (APVIA Ltd) is committed to promoting equality, diversity, and inclusion in all aspects of its operations in Sierra Leone. We believe that a diverse and inclusive workforce strengthens our organisation, enhances our service delivery, and reflects the communities in which we operate.
Read PolicyRef: APVIA-POL-MS-001
Modern Day Slavery Policy
African Projects Ventures Investments and Advancement Limited (APVIA Ltd) has zero tolerance for modern slavery and human trafficking in any part of our business or supply chains. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chains.
Read PolicyRef: APVIA-POL-001
Complaint Policy
This policy establishes the framework for receiving, investigating, and resolving complaints made against APVIA Ltd, its directors, employees, agents, or operations in Sierra Leone. It ensures complaints are handled fairly, transparently, and efficiently, with accessible channels for stakeholders to raise concerns without fear of retaliation.
Read PolicyQuestions About This Policy?
If you have any questions, please do not hesitate to contact us.
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